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Chemical Superfund Excise Taxes Reinstated, Increased and Expanded by US Infrastructure Act; House-Passed Build Back Better Act Proposes Reinstatement of Superfund Excise Tax on Crude Oil and Petroleum Products

USA - November 22 2021 On November 15, 2021, President Biden signed H.R. 3684, the Infrastructure Investment and Jobs Act (the "Infrastructure Act"), into law. The…

Kenneth Klein, Shawn R. O'Brien, Stephanie Wood

IRS Memo on 482 Adjustments for CSAs with Reverse Claw-Back Provisions

USA - July 20 2021 After Altera’s victory in Tax Court in 2015, many companies with cost sharing arrangements (“CSA”) ceased sharing stock-based compensation (“SBC”)…

Paul DiSangro

Déjà Vu All Over Again: Life Sciences Companies Brace for More US and Global Tax Reform

USA - April 6 2021 The 2017 Tax Cuts and Jobs Act (TCJA) made sweeping changes to the Internal Revenue Code (Code). When coupled with the implementation of the various…

Lucas Giardelli, Kenneth Klein, Michael Lebovitz, Jason M. Osborn, Warren S. Payne, Reb D. Wheeler

COVID-19 Travel Restrictions: US Tax Relief and Cross-Border Tax Considerations

USA - May 11 2020 COVID-19 has left employee workforces separated from their country of assignment. To continue operations, employers transitioned employees…

Michael Lebovitz, Jonathan A. Sambur, Xiao Xiao

IRS Issues Proposed Regulations for Calculating UBTI from Separate Unrelated Trades or Businesses

USA - May 4 2020 On April 24, the US Internal Revenue Service (the “IRS”) issued proposed regulations1 (the “Proposed Regulations”), which clarify how tax-exempt…

James R. Barry, Jeffrey M. Bruns, Andre M. Smith II, Matthew A. McDonald, JoonBeom Pae